APAC INSIDER WEBSITE PRIVACY NOTICE

1. Introduction

This privacy notice is for:

• users of this website
• individuals who receive our marketing communications

This privacy notice informs you about how AI Global looks after your personal data when acting as controller.  It also explains your data protection rights and how the law protects that information.

Please refer to the glossary at the end of this privacy notice.

• Important information and who we are

It is important that you read this privacy notice together with any other notice we may provide when we collect or process your personal data.

Controller

APAC Insider is a brand owned by AI Global Media Ltd.  AI Global Media Ltd is the controller and responsible for your personal data (collectively referred to as “AI Global”, “we”, “us”, or “our” in this privacy notice).

We have appointed a person to be responsible for responding to questions in relation to data protection.  If you have any questions about data protection, please contact us using the details below.

Contact details

Full name of legal entity: AI Global Media Ltd

ICO Registration: ZA196657

Registered company number: 07400916

Postal address:  Ground Floor, Suites B-D, The Maltsters, Wetmore Road, Burton-On-Trent, Staffordshire, DE14 1LS.

Telephone number: 0203 970 0010

Main email: [email protected]

Data protection / GDPR email: [email protected]

Data protection complaints

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO).  The ICO’s contact details are set out below.  We would, however, appreciate the chance to deal with your concerns before you approach the ICO.

The Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF

Website: www.ico.org.uk

Telephone number: 0303 123 1113 (local rate) or 01625 545 745 (national rate)

Changes to this privacy notice

This version was last updated on 07.06.2022.

Changes to your personal data

It is important that the personal data we hold about you is accurate and up to date.  Please keep us informed if your personal data changes during your relationship with us.

Third party links

Our website may include links to third party websites, plug-ins and applications.  Clicking on those links or enabling those connections may allow third parties to collect or share data about you.  We do not control those third party websites and are not responsible for them.  When you leave our website, we encourage you to read the privacy notice of each website you visit.

• The data we collect about you

Personal data means any information about an individual from which that person can be identified.  It does not include anonymised data.

We may collect, use, store and transfer the following categories of personal data about you:

•              Identity data includes first name and last name

•              Contact data includes business email address and telephone numbers

•              Technical data includes internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology you use to access our website

•              Usage data includes information about how you use our website, products or services

•              Marketing and communications data includes your preferences in receiving marketing from us and your communications preferences

We also use collect, use, store or transfer Aggregated data such as statistical or demographic data for any purpose.  Aggregated data may be derived from personal data, but it is not considered personal data in law as the information will not directly or indirectly identify you.

We do not collect any Special categories of personal data about you (personal data revealing: racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data, health, sex life or orientation).  Nor do we process any Criminal offence data.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to enter into or perform the contract.  In such a case, we may have to cancel a product or service you have with us.

• How is your personal data collected?

We may use different methods to collect data from and about you including through:

Direct interactions

You may give us your Identity and Contact data by completing forms or by corresponding with us.  This includes personal data you provide when you:

• apply for our products or services
• create an account on our website
• subscribe to our services or publications
• request marketing
• enter a competition, promotion or survey; or
• provide feedback or contact us

Automated technologies or interactions

As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns.  We collect this personal data using cookies, server logs and other similar technologies.  We may also receive Technical data about you if you visit other websites employing our cookies.  Please see our cookie policy https://www.apac-insider.com/cookie-policy/ for further details.

We, and third parties (see below), may use your personal data and cookies for advertising personalization and measurement.

Third parties or publicly available sources

We will receive personal data about you from various third parties as set out below

• Technical data from the following parties:
  • Analytics providers such as Google Analytics – https://analytics.google.com/
  • Advertising display platform operated by Google Adsense https://support.google.com/adsense
  • Affiliate networks operated by Awin Limited https://www.awin.com/gb and Commission Junction LLC https://www.cj.com/
  • Search information providers such as SalesQL – https://salesql.com/, LinkedIn Sales Navigator – https://business.linkedin.com/
  • Identity and contact data from:
    • publicly available sources such as Companies House and and business social media pages such as FaceBook – https://www.facebook.com/
• How we use your personal data

We will commonly use your personal data in the following circumstances:

• where we need to perform the contract we are about to enter into or have entered into with you.
• where it is necessary for our legitimate interests (or those of a third party) any your interests and fundamental rights do not override those interests
• where we need to comply with a legal obligation
• where we have your consent e.g. to send third party direct marketing to you via email or text message.  Please note that you have the right to withdraw consent to marketing at any time by contacting us.

Click here https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/lawful-basis-for-processing/ to find out more about the types of lawful basis that we may rely on to process your personal data.

Purposes for which we will use your personal data

The table below sets out how we will use your personal data and the relevant legal bases.  We have also identified what our legitimate interests are where appropriate.  We may process your personal data for more than one lawful ground depending on the specific purpose. 

Marketing

We strive to provide you with choices regarding the use of your personal data, in particular around marketing and advertising.  We have included an opt out/unsubscribe form where you can choose to stop receiving further communications. You can find this HERE

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you.

You will receive marketing communications from us if you have requested information from us and you may receive marketing communications from us if we are legally permitted to make unsolicited contact with you. We will not contact you if you have opted out of receiving that marketing.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes. 

For information on how Google will use your information with regards to the personalization of adverts on our website, please view Google’s Privacy & Terms site.

Opting out

You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

The websites of third parties (listed above) may offer you the opportunity to opt out of their use of cookies for personalised advertising.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you would like an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

• Disclosure of your personal data

We may share your personal data with the parties set out below for the purposes set out in section 5 above.

• External Third Parties as set out in section 10 below.
• Third parties to whom we may choose to sell, transfer, or merge parts of our organisation or our assets. Alternatively, we may seek to acquire other organisations or merge with them. If a change happens to our organisation, then the new owners may use your personal data in the same way as set out in this privacy notice.

All third parties are required to respect the security of your personal data and to treat it in accordance with the law.

• Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting, or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

• Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

• Glossary

Lawful basis

• means processing your personal data where it is necessary for compliance with a legal, regulatory, tax, accounting or other requirementsthat we are subject to.
• means the data subject has given clear consent for us to process their personal data for a specific purpose.
• means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Third parties

External third parties

• Service providers who provide IT and system delivery/administration services.
• Professional advisers who provide, for example, accountancy and legal services.
• Regulators and other authorities who may require reporting of processing activities in certain circumstances.

Digital Fingerprint Tracking

Alongside Cookies, we also use Digital Fingerprint Tracking to collect data about the users of our websites, including the IP address, browser, operating system, country and referrer. The data collected is intended for internal usage only and will not be shared or sold externally. The aim of this is to gain better insights into our visitors so ultimately, we can enhance the end users experience on our website. If you have any questions regarding this, or you previously accepted this on our consent banner but would now like to revoke consent / your data, please contact us at: [email protected].